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On or about January 25, 1991, the Boyers entered into an
installment agreement to pay the 1986 tax liability (the 1986
installment agreement). The Boyers made payments pursuant to the
1986 installment agreement for almost 8 years. The Boyers
stopped making payments, in default of the 1986 installment
agreement, on October 5, 1998.
The Boyers filed an untimely joint Federal income tax return
for 1987 on June 6, 1988 (the 1987 return). On the basis of the
1987 return, respondent assessed $8,444 in income tax, $456 as an
addition to tax for failure to pay estimated tax under section
6654, $84 as an addition to tax for failure to pay timely the
amount shown as tax on the return under section 6651(a)(2), plus
interest (the 1987 tax liability). Respondent filed a Tax Lien
Notice regarding the 1987 tax liability on August 8, 1989, and
almost 5 years thereafter, the Boyers entered into an installment
agreement to pay the 1987 tax liability (the 1987 installment
agreement). The Boyers made payments pursuant to the 1987
installment agreement for 4 years but stopped making payment, in
default of the 1987 installment agreement, on February 2, 1998.
Respondent failed to refile a tax lien notice as required by
section 6323(g) regarding the 1987 liability.
On November 7, 1997, the Boyers signed a Form 900, Tax
Collection Waiver, relating to the 1986 and 1987 tax liabilities.
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